FIRST DEVELOP Co., Ltd. (hereinafter referred to as “the Company”) conducts business related to the planning, design, construction, and maintenance of computer systems as an information service company.

In advancing our business, we recognize the importance of personal information (including specific personal information) and position activities for the protection of personal information as a fundamental activity of our company.

We recognize that the sincere execution of personal information protection efforts is a social responsibility, and we establish the following personal information protection policy, disseminate it to officers, employees, and collaborators, and thoroughly implement it:

1. Proper acquisition, use, provision, and outsourcing of personal information:
   1) The acquisition of personal information is conducted within the scope of our business, and unless there is a risk of impairing the rights and interests of the individual or a third party, we will clearly state the purpose of use to the individual and acquire consent before doing so. Acquired personal information will not be used for purposes other than the stated purpose, and its use will be limited and handled appropriately.
   2) Except for orders based on laws and regulations, we will not provide personal information to third parties without obtaining the prior consent of the individual.
   3) When outsourcing personal information to a third party, we will select a party with a sufficient level of personal information protection, specify the protection level through contracts, etc., and provide guidance and management to ensure proper handling.
2. Procedures for responding to requests for disclosure, correction, and suspension of use, etc., of personal information:
   We will promptly respond to requests from individuals regarding personal information held by the Company.
3. Prevention and correction of the loss, damage, leakage, and unauthorized access of personal information:
   The Company strictly manages personal information, implements preventive measures against all risks such as loss, destruction, alteration, leakage, and unauthorized access, and conducts regular audits and necessary corrective measures. Specific rules regarding the proper handling and operation of personal information will be established, and responsible persons will be designated.
4. Compliance with laws and regulations concerning personal information and other standards:
   Officers, employees, and collaborators of the Company will comply with laws, regulations, guidelines, and other related standards regarding personal information protection and the confidentiality of communications.
5. Continuous improvement of the personal information protection policy and internal regulations:
   The Company will continuously improve the personal information protection management system to ensure that personal information protection requested by society is effectively implemented.
6. Inquiries regarding the handling of personal information:
   We will promptly respond to complaints, consultations, etc., from individuals at the following contact point.

December 26, 2022
FIRST DEVELOP Co., Ltd.
Representative Director
Zhang Yong

[Contact Point]
FIRST DEVELOP Co., Ltd.
Administration Department
info@firstdevelop.com